The introduction of the U.K. Environment Bill in January 2020 signaled a decisive shift in how the government plans to regulate packaging waste and resource efficiency across fast-moving consumer goods (FMCG) and beverage industries. While the Bill itself remains under parliamentary consideration, its proposed provisions on extended producer responsibility (EPR) have already prompted companies to assess their packaging supply chains in anticipation of stricter due diligence and reporting requirements. For firms aiming to stay ahead of the compliance curve, 2020 represents a crucial window for preparation—one that hinges not only on internal process improvements but also on leveraging publicly available data to map and monitor packaging inputs effectively.
At the heart of the anticipated EPR framework is a drive to hold producers more accountable for the environmental impact of packaging throughout its lifecycle. Under current proposals, producers of packaged goods will bear greater financial and operational responsibility for the recovery and recycling of packaging materials. What distinguishes this new approach from existing obligations is the granular traceability it demands: companies will need to demonstrate a clear understanding of the materials used, their sources, and their eventual destination within the waste stream. This is no small task, particularly for businesses with diverse supplier networks spanning multiple jurisdictions and packaging types.
One of the most practical starting points for companies is to begin mapping packaging materials using open data sources such as the ValPak packaging compliance scheme database. The ValPak database offers detailed insights into the types and quantities of packaging placed on the U.K. market, as well as recycling and recovery rates by material category. By cross-referencing internal procurement data with ValPak’s figures, companies can benchmark their current packaging profile against national trends, identify high-risk materials, and prioritize areas for intervention. For example, firms heavily reliant on composite or hard-to-recycle plastics can use these insights to inform supplier engagement strategies or material substitution efforts.
Mapping supplier packaging materials is not just an exercise in data gathering—it is the foundation for credible pilot reporting. The Environment Bill’s anticipated timeline suggests that producers will be expected to submit preliminary EPR metrics to the Department for Environment, Food and Rural Affairs (DEFRA) by the end of 2020. These metrics, though not yet legally mandated, will likely set the tone for formal reporting obligations once the Bill is enacted. A sensible approach for companies involves establishing internal reporting templates now, capturing data on packaging material type, supplier name and location, quantity supplied, and end-of-life treatment method (e.g., recyclable, compostable, landfill).
In practical terms, businesses should consider setting quarterly milestones for data collection and validation. The first quarter could focus on supplier outreach and data consolidation, ensuring that information on packaging materials is collected in a consistent format. The second quarter might involve analysis and internal benchmarking, using ValPak data to contextualize findings. By the third quarter, firms could move towards preparing pilot reports, stress-testing internal processes and identifying gaps. The final quarter of 2020 should see the submission of pilot metrics to DEFRA, positioning companies as proactive participants in shaping future regulatory frameworks.
Beyond technical compliance, early action on packaging due diligence offers reputational advantages. With public scrutiny of packaging waste at an all-time high, companies that can demonstrate tangible progress toward EPR readiness will be better placed to engage consumers, investors, and regulators. The narrative is as much about transparency and responsibility as it is about technical compliance. By publishing high-level summaries of packaging material audits or piloting supplier scorecards, firms can reinforce their commitment to sustainable packaging at a time when such commitments are under the spotlight.
To be sure, uncertainties remain. The precise scope and structure of the Environment Bill’s EPR provisions are still subject to parliamentary debate and stakeholder consultation. However, the direction of travel is clear. Companies that act now—by mapping supplier packaging materials, leveraging open data sources like ValPak, and submitting pilot EPR metrics—will not only ease their transition to future legal requirements but also help shape a more circular economy for packaging in the U.K.